Day 094 - 01 Mar 95 - Page 02

     1                     DR. GOMEZ GONZALEZ, recalled
     2             Cross-examined by the Defendants, continued.
     4   MS. STEEL:   Before we start, can I just hand in the rest of the
     5        article that Mr. Rampton asked for yesterday?
     7   MR. JUSTICE BELL:  Yes.
     9   MS. STEEL:   It came in the post this morning actually.
    11   MR. MORRIS:  Yesterday we finished off we were looking through
    12        the documents from McDonald's process plant, Tysons.  This
    13        was relating to chicken products, was it not?  I do not
    14        think you need to read that now.  We were looking at the
    15        Tysons forms, US DA inspection forms, for the chicken
    16        process plant?
    17        A.  That is correct.
    19   Q.   Have you got them in front of you?
    20        A.  Yes, I do.
    22   MR. JUSTICE BELL:  Perhaps when we have a break someone in your
    23        team, Mr. Rampton, could help Mr. Riley get those articles
    24        behind Miss Druce's statement?
    26   MR. RAMPTON:  Yesterday's have been done, today's have not yet.
    28   MR. JUSTICE BELL:  I am not sure they have all actually got in.
    30   MR. MORRIS:  We were looking at the non-conformity results or
    31        criticisms from the inspectors of the US DA.  On page 53,
    32        we might as well go back to page 53, there was 74 per cent
    33        non-conformity for training employees and 95 per cent
    34        non-conformity for equipment disassembly.  Have you seen
    35        this type of form before?
    36        A.  I have used  -- yes, I have -- I have used this system
    37        quite a lot.  I used to work in a poultry processing plant
    38        and I am very well familiar with the terminology.
    40   Q.   You said yesterday that disassembling equipment, the
    41        sanitation implications are very important.  If there is a
    42        95 per cent criticism, whether it is minor, major or
    43        critical, and you will notice that some of them are
    44        critical criticisms in their definition, 15 out of 64
    45        checks, would McDonald's expect or do something about the
    46        conditions at its suppliers?  First of all, would it be
    47        made aware of this by the suppliers?
    48        A.  Absolutely.
    50   Q.   What would you expect to happen? 
    51        A.  From seeing this data, what my reaction would be? 
    53   Q.   What would you expect the supplier plant to do or your
    54        department to do, faced with this?
    55        A.  OK.  From looking at this data, what it does and the
    56        evidence you have provided, the consumer complaints that we
    57        have discussed in the past, what it does tell me is that
    58        this particular plant, Tyson plant, at Nashville, could not
    59        be any better.  I have never seen such good evidence that
    60        would support our case.

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